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April 21, 2020 Via the SEC Portal Ms. Vanessa Countryman Office of the Secretary U.S. Securities and Exchange Commission 100 F

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April 21, 2020 Via the SEC Portal Ms. Vanessa Countryman Office of the Secretary U.S. Securities and Exchange Commission 100 F April 21, 2020 Via the SEC Portal Ms. Vanessa Countryman Office of the Secretary U.S. Securities and Exchange Commission 100 F. Street NE Washington, D.C. 20549 Re: Comment Letter to SEC Release No. 34-88474; File No. SR-NSCC-2020-003 Dear Ms. Countryman: Alpine Securities Corporation (“Alpine”) hereby submits its comment letter to SEC Release No. 34- 88474, File No. SR-NSCC-2020-003 (the “Proposed Rule”). Background of Alpine Alpine is a small, self-clearing broker-dealer, registered with the SEC. Alpine’s business primarily involves trading, clearing and settlement services for microcap and over-the-counter (“OTC”) stock transactions for other brokerage firms. Brokers who are not members of the registered clearing agency need the services of a clearing broker in order to clear and settle their own trades or the trades of their customers. To provide clearing and settlement services and function as a clearing firm for its correspondent firms, Alpine must be a member of NSCC and access its services. Alpine is a clearing broker member in good standing of the NSCC and a DTC participant. Alpine’s primary mission is to provide liquidity to the microcap OTC market. There are more than 10,000 stocks trading on the OTC markets, while the number of listed companies is about 4,397 as of 2018. Alpine is one of a few broker-dealers to fully service this important market segment that represents the core of the US economy and jobs. Alpine facilitates tens of millions of dollars of capital financing for small business each month through the deposit, clearance and liquidation of microcap securities on behalf of its correspondent customers who provide direct financing to thousands of innovative, startup business that operate in the US. In October 2018, Forbes published an article titled “The End of the Penny Stock Market Could Be Imminent.” The penny stock market is just another name for the microcap OTC market. The article reports that mainstream firms like Merrill Lynch, Morgan Stanley and UBS have stopped accepting penny stock deposits. The articles states that “Because of restrictions imposed by FINRA and the SEC, microcap funders cannot, for all intents and purposes, deposit paper certificates with major clearing firms.” In addition, major online discount firms (e.g., E-Trade, Charles Schwab, etc.) do not process this business either. In December of 2018, Alpine filed an Application for Review and a Rulemaking Petition (copy attached) to the SEC regarding certain of NSCC’s charges, fees and required fund deposit. Those petitions remain pending, and NSCC has recently requested that the SEC stay consideration of the Application for Review as a result of the filing of the Proposed Rule. However, because Alpine’s concerns about the application of the Proposed Rule mirrors in many ways Alpine’s concerns about the way NSCC is applying its current rules to calculate the required fund deposit charges to Alpine and other similarly situated small firm members, Alpine has attached the key documents from its previous filings hereto which discuss in greater detail the discriminatory impacts the Proposed Rule will have on smaller broker-dealers operating in the OTC space. 39 Exchange Place | Salt Lake City, UT 84111 p (801) 355-5588 | f (801) 355-5742 | toll free (800) 274-5588 | alpine-securities.com Member FINRA & SIPC SEC Rel. No. 34-88474/ SR-NSCC-2020-003 April 22, 2020 Page 2 of 4 Concerns over the Impact of the Volatility Charge The Proposed Rule seeks to “enhance the calculation of the haircut-based volatility component of the Clearing Fund methodology for Net Unsettled Positions in securities whose trading volume and therefor volatility is less adaptable to statistical analysis than securities whose volatility is amendable to generally accepted statistical analysis only in a complex manner.” Proposed Order, at pp. 3-4. Alpine is appreciative and supportive of the fact that NSCC is vigilant in monitoring, evaluating and addressing potential credit and other risks. However, Alpine has concerns with the manner in which these risk management strategies are being developed and employed insomuch as they disproportionately impact smaller broker-dealer members and small companies whose stock does not trade on the “right kind” of exchanges like the NASDAQ or NYSE. More and more frequently now, these impacts intersect because the independent broker-dealers and clearing firms, such as Alpine, are the only ones willing to process these microcap stocks given the large associated transactional and regulatory costs. Unfortunately, the Proposed Rule heightens these concerns. The volatility charge formulas in the Proposed Rule are overly complicated and appear to be subject to discretionary and behind-the-door decisions by NSCC. Alpine was in the process of a Rulemaking Petition in order to stop the NSCC charges which were so unconscionably high that they were impossible to justify as being a necessary or even reasonable means to protect against any conceivable or probable loss. Alpine provided the SEC with specific example of fees and charges exceeding the underlying transaction value by over 200 times. While it is difficult to understand the complex and vague calculation of the volatility charge in the Proposed Rule, it is clear that the changes are substantially worse than what NSCC is currently charging. During March of 2019, Alpine received an email from Anthony Baglio Jr., of DTC, attaching a White Paper outlining the proposed changes the volatility component and an additional breakdown of the amounts Alpine would have been charged during that last year under the proposed changes. The White Paper is attached hereto. Mr. Baglio summed up the changes in his email stating that “the estimated impact of the change is a daily clearing fund requirement increase of approximately 198% ….” NSCC is claiming that it is only trying to mitigate against potential losses, but the charge itself does not bare any rational semblance to the transaction value, or any conceivable and verifiable risk from the particular transaction, because it exceeds it by many multiples. NSCC has not provided any support to justify the excessive charges and fees for a potential loss, other than the assertion of an unproven mathematical theory. Below illustrates the absurdity of the NSCC Deposit Requirement formula, albeit under the current rule. The Proposed Rule exasperates the calculations. One such trade involved 198,000 shares of stock held long at DTC and priced at $.02/share for total market value of $4,016. To process this trade through CNS, NSCC required Alpine to deposit $928,175 in the Clearing Firm Deposit. This required deposit must be sent to NSCC by 9 am the next day and it is held at NSCC until the trade settles. Alpine made about $300 commission on the trade. Presumably, as mentioned, the required deposits are to cover risks associated with a failure to deliver by the selling broker. The requirement takes no notice of the fact that Alpine has already cleared the underlying security with DTC, NSCC’s affiliated company nor does it take into consideration that the trade is “locked-in” with the counter party on CNS. In other words, Alpine is long the position at DTC and the parties are bound by the sale terms at the time of sale, which reduces the trade default risk to zero. The net effect of the Proposed Rule, and Alpine’s fears this is the very purpose of the Proposed Rule, is to destroy the microcap securities market and small firms like Alpine that service this space by increasing the costs, and thus the amount of necessary capital, to provide clearing services in this space to an unsustainable level. Alpine is one of the largest, by volume, broker dealers that clears, settles, and liquidates microcap securities that trade in the OTC market. Thus, Alpine’s services are essential to small business access to capital. Large street firms and banks do not typically provide investment banking and financing services to this segment of the market. And certainly, today, small business access to capital is more critical in light of the COVID-19 pandemic and associated economic fallout. SEC Rel. No. 34-88474/ SR-NSCC-2020-003 April 22, 2020 Page 3 of 4 Because Alpine is one of the largest operators in this space who will be directly and negatively impacted by the Proposed Rule, analysis of the Proposed Rule’s impact on Alpine should carry great weight. Alpine’s Application for Rule Making Petition challenges the NSCC’s calculation of the required fund deposit, including the Illiquid Charge, Excess Net Capital Charge, and special formulas for calculating volatility and mark-to-market charges for transactions involving microcap stocks traded on the OTC market. Alpine comprehensively detailed, supported by declarations, that the impact will result in unsustainable harm to Alpine’s business which, alone, will have a large impact on the clearing of OTC securities. The Proposed Rule results in even higher charges and fees for Alpine. The Proposed Rule, if approved, will further limit access to NSCC’s essential clearing and settlement services. While NSCC’s efforts to mitigate risk is admirable, the risks must be real. Even then, the elimination of any possible market or credit risks, no matter how unlikely, is not the Commission’s primary mission in shepherding national market system. Promoting competition and capital formation are each central to the purpose of the Exchange Act. As Congress noted in amending the Exchange Act in 1975, which added Sections 17A and 19 to the Exchange Act, “it is in the public interest to assure . fair competition among brokers and dealers, among markets and between exchange markets and over-the-counter markets.”1 The goal is not to hinder, but to “enhance competition” and to “allow economic forces, interacting in a fair regulatory field, to arrive at appropriate variations in practices and services.”2 The Proposed Rule has a blatantly anticompetitive and discriminatory effect as applied, and serves to severely limit, rather than promote capital formation.
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